• What are the trust services sanctions and what activity is prohibited? Since 16 December 2022, regulation 18C under the Russia (Sanctions)(EU Exit) Regulations 2019 prohibits providing new trust services to individuals connected with Russia or designated under this measure, including potential future beneficiaries as defined in Regulation 18C(5).
• Is there a trust services General Licence? A General Licence (INT/2023/2589788) allows trust service providers 90 days to wind down services related to designated persons. Providers must report activities to OFSI within 30 days using the provided form. This licence is in addition to existing exceptions for complying with asset freezes.
• Do the trust services sanctions apply in the UK Crown Dependencies and Overseas Territories (OTs)? The sanctions apply to UK Crown Dependencies and Overseas Territories, supported by HM Treasury and Foreign, Commonwealth and Development Office . These territories can issue General Licences with the Foreign Secretary’s consent and a number of OTs may already mirror OFSI’s General Licence.
• Can a person provide professional and business services when operating or managing a trust? Regulation 54C prohibits providing professional and business services to persons connected with Russia unless permitted by a licence from the Export Control Joint Unit or under an applicable exception. Separate licences are required for trust services from the OFSI, and for professional/business services from the Department for Business and Trade.
• What happens when an asset freeze is in place - how do the trust services sanctions interact? Assets of designated persons must remain frozen under Regulation 11. Trust services may continue if necessary to comply with the asset freeze, under exception 60ZZB(1)(b), with appropriate licensing or exceptions.
• Whether the trust services sanctions cover the drafting of wills that contain trusts which may benefit a person connected with Russia, or whether the sanctions become relevant once the will trust comes into effect after the testator’s death? Since 16 December 2022, it is prohibited to provide new trust services to, or for, the benefit of persons connected with Russia, including those named in wills as potential beneficiaries.

For detailed guidance and further information, refer to the OFSI’s updated Russia guidance.

These updates clarify the scope and application of trust services sanctions, ensuring compliance with the latest regulatory measures.

FAQs 92-97 can be found under the OFIS’s Russia section, here.